Justia U.S. 6th Circuit Court of Appeals Opinion Summaries

After the death of Marjorie Johnson in 2020, her daughter, Rita Johnson, was appointed as executrix of her estate by the Wayne County, Michigan probate court. Rita initiated probate proceedings to determine whether certain assets belonged to the estate or to the Johnson Family Trust, which had a provision requiring arbitration of disputes. Amos C. Johnson, Marjorie’s son and trustee of the Trust, sought to compel arbitration in state court, but the request was denied. Subsequently, Amos and the Trust filed suit in the United States District Court for the Eastern District of Michigan, seeking to compel arbitration of the probate dispute under § 4 of the Federal Arbitration Act (FAA).The district court ordered the plaintiffs to show cause why the case should not be dismissed for lack of subject matter jurisdiction, citing the probate exception, the prior-exclusive-jurisdiction doctrine, and potential lack of diversity. The court ultimately dismissed the case, finding that the FAA does not provide an independent basis for federal question jurisdiction and that the probate proceedings were in rem, meaning the federal court would improperly interfere with property under the state probate court’s control.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit held that federal courts may only compel arbitration under § 4 of the FAA if they would have jurisdiction over the underlying dispute. Because the probate proceedings were purely matters of state law and involved property already under the state court’s jurisdiction, the federal court lacked both federal question and diversity jurisdiction. The Sixth Circuit affirmed the district court’s dismissal, holding that the federal court did not have subject matter jurisdiction to compel arbitration of the state probate proceedings. View "Johnson v. Johnson" on Justia Law

A group of Black farmers and their association, along with several individual members, sought to file claims with the U.S. Department of Agriculture (USDA) for financial assistance under a program created by the Inflation Reduction Act of 2022. They wished to submit applications on behalf of deceased relatives who had allegedly experienced discrimination in USDA farm lending programs. The USDA, however, had a policy that excluded applications reporting only discrimination against individuals who were deceased at the time of application, making such claims ineligible for the program.The plaintiffs filed suit in the United States District Court for the Western District of Tennessee, seeking an injunction to require the USDA to accept these “legacy claims.” The district court denied their motion for a preliminary injunction and granted the government’s motion to dismiss under Rule 12(b)(6), holding that the relevant statute only authorized financial assistance to living farmers. The plaintiffs appealed this decision to the United States Court of Appeals for the Sixth Circuit and also sought an emergency injunction pending appeal, which was denied.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the statutory language of § 22007(e) of the Inflation Reduction Act required the USDA to provide “assistance” to farmers who experienced discrimination, and that “assistance” was forward-looking and could not be provided to deceased individuals. The court found that the statute did not authorize compensation for past harm to deceased farmers, distinguishing “assistance” from “compensation.” The court affirmed the district court’s judgment and denied the motion for an injunction pending appeal as moot, holding that the USDA was required to reject applications filed on behalf of deceased farmers. View "Black Farmers & Agriculturalists Ass'n v. Rollins" on Justia Law

Diego Pavia, a college football player, sought to play for Vanderbilt University during the 2025 season. After a successful 2024 season, Pavia faced ineligibility under National Collegiate Athletic Association (NCAA) rules, which limit athletes to four seasons of intercollegiate competition, including seasons played at junior colleges. Pavia’s path included time at a junior college, New Mexico State University, and Vanderbilt. The NCAA counted his 2021 junior college season toward his eligibility, effectively barring him from playing in 2025. Pavia argued that this rule violated the Sherman Act and sought injunctive relief to allow him to play in the 2025 and 2026 seasons.The United States District Court for the Middle District of Tennessee granted Pavia a preliminary injunction, preventing the NCAA from enforcing the rule against him for the 2025 season and from applying its restitution rule to Vanderbilt or Pavia based on his participation. The NCAA appealed this decision to the United States Court of Appeals for the Sixth Circuit.While the appeal was pending, the NCAA issued a waiver allowing all similarly situated athletes, including Pavia, to play in the 2025 season. The NCAA confirmed that this waiver would remain in effect regardless of the outcome of the appeal. The United States Court of Appeals for the Sixth Circuit determined that, because Pavia had already received the relief he sought at the preliminary injunction stage, the appeal was moot. The court held that it could not grant any further effectual relief and dismissed the appeal for lack of jurisdiction. The court also declined to vacate the preliminary injunction, finding that the NCAA’s own actions had caused the case to become moot. View "Pavia v. NCAA" on Justia Law

A married couple, both employees of UT-Battelle, objected to their employer’s COVID-19 vaccine mandate on religious grounds, specifically because of their belief that the vaccines’ development involved the use of fetal cell lines from abortions, which conflicted with their Christian faith. UT-Battelle required employees seeking religious exemptions to undergo a panel interview and read a “fact sheet” presenting religious leaders’ support for vaccination. Employees granted religious accommodations were placed on unpaid leave, while those with medical accommodations were not. Mrs. Bilyeu ultimately received a medical exemption before the policy took effect and did not lose pay or work time. Mr. Bilyeu, however, was placed on unpaid leave after exhausting his vacation days, returning to work only after the policy was rescinded.The United States District Court for the Eastern District of Tennessee granted summary judgment to UT-Battelle on all claims except Mrs. Bilyeu’s retaliation claim, which was later settled. The court found that Mrs. Bilyeu lacked standing and that Mr. Bilyeu had not suffered a materially adverse employment action under Title VII.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment as to Mrs. Bilyeu, holding she lacked Article III standing because she suffered no cognizable injury after receiving her medical accommodation. For Mr. Bilyeu, the Sixth Circuit vacated the summary judgment on his disparate treatment and failure-to-accommodate claims, instructing the district court to reconsider them in light of the Supreme Court’s decision in Muldrow v. City of St. Louis, which eliminated the “materially adverse” requirement for adverse employment actions under Title VII. The court reversed the summary judgment on Mr. Bilyeu’s retaliation claim, finding sufficient evidence for a reasonable jury to conclude that the interview process could dissuade a reasonable worker from seeking a religious accommodation, and remanded for further proceedings. View "Bilyeu v. UT-Battelle, LLC" on Justia Law

In this case, Christopher C. Brown, through his company Tattooed Millionaire Entertainment (TME), owned a Memphis music studio and insured both the studio and its equipment with Hanover American Insurance Company. John Falls, a musician, leased Studio B and its equipment from Brown and also obtained insurance from Hanover for the equipment and lost business income. In 2015, the studio was damaged by arson, and both Brown and Falls submitted insurance claims. Hanover discovered Brown had forged receipts for equipment purchases and sued to recover advance payments and for a declaratory judgment of no further liability. Brown, Falls, and another lessee counter-sued for breach of contract. After a jury trial in the United States District Court for the Western District of Tennessee, Falls was awarded $2.5 million for equipment loss and $250,000 for business income, while Brown was found to have committed insurance fraud.Hanover moved to set aside the verdict under Rule 50(b), which the district court granted. On appeal, the United States Court of Appeals for the Sixth Circuit reversed, holding Hanover had forfeited its Rule 50(b) motion by failing to make a Rule 50(a) motion as to Falls, and ordered reinstatement of the jury verdict. Subsequent proceedings included a federal interpleader action and a parallel state court action between Falls and TME. The district court enjoined the state action, but the Sixth Circuit reversed the injunction.In the present appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s allocation of the insurance payout, holding that Hanover was precluded by res judicata from challenging Falls’s recovery on grounds that could have been raised earlier. The court found the district court’s error in interpreting the wrong lease was harmless and upheld the allocation of funds based on the value of Falls’s leasehold interest. The court also held that Tennessee public policy barred Brown from recovering his allocated share due to his insurance fraud. The district court’s judgment was affirmed. View "Hanover American Insurance Co. v. Tattooed Millionaire Entertainment" on Justia Law

The founder and former CEO of a national pizza company brought suit against a public relations firm that had previously provided services to the company. The dispute arose after the plaintiff alleged that the firm leaked confidential and damaging information about him to the press, in violation of a nondisclosure agreement (NDA) that included an arbitration clause. The NDA was executed after the company requested the firm sign it, anticipating close work with the plaintiff during a period of reputational crisis. The relationship between the parties deteriorated following a conference call in which the plaintiff made controversial remarks, which were later reported in the media, leading to his resignation from the company’s board.The case was initially filed in state court and then removed to the United States District Court for the Western District of Kentucky. Over several years, the litigation involved multiple amended complaints, extensive discovery, and dispositive motions. The defendant did not move to compel arbitration until after the district court denied summary judgment on the NDA claim. The district court held a bench trial and found that the NDA was enforceable and contained a binding arbitration provision. However, the court concluded that the defendant had defaulted on its right to arbitrate by actively litigating the case for years before seeking arbitration, and thus denied the motion to compel arbitration.On appeal, the United States Court of Appeals for the Sixth Circuit determined it lacked jurisdiction to review the district court’s contract formation ruling but had jurisdiction to review the default determination. The Sixth Circuit affirmed the district court’s finding that the defendant defaulted on its arbitration rights by seeking a merits resolution in court before moving to compel arbitration. The court dismissed the appeal in part for lack of jurisdiction, otherwise affirmed the district court’s judgment, and denied the plaintiff’s request for sanctions. View "Schnatter v. 247 Group, LLC" on Justia Law

A group consisting of a local chapter of a national organization and two individuals challenged certain rules governing public comment at Wilson County Board of Education meetings in Tennessee. The Board’s policies required speakers to disclose their names and addresses, limited comments to certain topics, and included a restriction on “abusive” comments as read by the Chair at meetings. The plaintiffs alleged that these rules deterred them from fully expressing their views, particularly regarding controversial school policies, and that they feared enforcement of the address-disclosure and abusive-comments rules. One plaintiff was stopped from speaking at a meeting for refusing to provide her address.The plaintiffs filed suit in the United States District Court for the Middle District of Tennessee, seeking to enjoin enforcement of three rules: the public-interest provision, the address-disclosure requirement, and the abusive-comments restriction. After the suit was filed, the Board removed the address-disclosure and abusive-comments rules from its policies and meeting materials. The district court denied the plaintiffs’ motion for a preliminary injunction, finding they had not shown a likelihood of success on the merits regarding the public-interest provision, nor a likelihood of imminent and irreparable harm from the other two rules, since they had been rescinded.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of a preliminary injunction. The court held that the plaintiffs lacked standing to challenge the public-interest provision because they had not shown a credible threat of its enforcement. As to the address-disclosure and abusive-comments rules, the court found that, because the Board had rescinded these rules and committed not to reinstate them during the litigation, the plaintiffs could not show a likelihood of imminent and irreparable harm necessary for preliminary injunctive relief. The case was remanded for further proceedings. View "Moms For Liberty - Wilson County, Tenn. v. Wilson Cnty. Bd. of Educ." on Justia Law

The petitioner, a taxpayer, received a notice of deficiency from the Internal Revenue Service (IRS) regarding her 2022 tax return. The IRS determined that she was not entitled to certain tax credits and imposed penalties. The notice, dated May 30, 2023, was sent to her former address, and she did not become aware of it until after the deadline to contest the deficiency had passed. She filed a petition for redetermination with the United States Tax Court on November 1, 2023, well after the ninety-day deadline specified in the Internal Revenue Code. In her petition, she argued that she was entitled to the disputed credits and status, and requested equitable tolling of the filing deadline due to her lack of timely notice.The United States Tax Court dismissed her petition for lack of jurisdiction, holding that the ninety-day deadline in I.R.C. § 6213(a) was a strict jurisdictional requirement that could not be extended or tolled, regardless of the circumstances. The court relied on prior Sixth Circuit precedent that had characterized the deadline as jurisdictional and rejected the petitioner’s arguments for equitable tolling.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the Tax Court’s dismissal de novo. The Sixth Circuit held that, in light of recent Supreme Court guidance, the ninety-day deadline in § 6213(a) is not a jurisdictional rule but rather a nonjurisdictional claims-processing rule. As such, it is presumptively subject to equitable tolling. The court reversed the Tax Court’s dismissal and remanded the case for the Tax Court to consider, in the first instance, whether the petitioner is entitled to equitable tolling of the filing deadline based on the specific facts of her case. View "Oquendo v. Comm'r of Internal Revenue" on Justia Law

William Plott suffered severe, lifelong disabilities as a result of a vaccine administered in infancy. His family sought compensation under the National Vaccine Injury Compensation Program, filing a petition in the United States Court of Federal Claims. A special master determined that Plott’s parents were entitled to monetary relief for his care and ordered the Department of Health and Human Services (HHS) to pay a lump sum and to purchase an annuity from Wilcac Life Insurance Company, with annual payments to be made to Plott’s estate. After Plott’s death, his estate sought a final annuity payment, which Wilcac refused to pay, prompting the estate to sue both HHS and Wilcac.The estate initially filed suit in the Hamilton County, Ohio, Court of Common Pleas. Wilcac removed the case to the United States District Court for the Southern District of Ohio. HHS moved to dismiss for lack of subject matter jurisdiction, and the district court granted this motion, dismissing HHS from the case. Wilcac then argued that HHS was a necessary and indispensable party under Federal Rule of Civil Procedure 19, and the district court agreed, dismissing the entire case without prejudice because HHS could not be joined without defeating subject matter jurisdiction.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s application of Rule 19. The appellate court held that the district court erred by applying a bright-line rule that all parties to a contract are necessary and indispensable under Rule 19. Instead, the court emphasized that Rule 19 requires a pragmatic, case-specific analysis. The Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings, instructing the lower court to conduct a proper Rule 19 analysis based on the specific facts of the case. View "Estate of William Plott v. Health and Human Services" on Justia Law

After the collapse of a federally chartered credit union in Ohio in 2010, the National Credit Union Administration Board (the Board) was appointed as liquidating agent. The Board sued Eddy Zai, his wife Tina Zai, and related entities to recover tens of millions of dollars allegedly owed to the credit union. The parties settled, with the Zais agreeing to transfer a promissory note to the Board, which would collect $22 million and then transfer the note to Tina Zai. Years later, Tina Zai alleged that the Board breached the settlement by failing to timely transfer the note after collecting the agreed sum. She, along with Stretford, Ltd., filed suit against the Board for breach of contract and unjust enrichment.The United States District Court for the Northern District of Ohio dismissed the case for lack of subject-matter jurisdiction, without reaching the merits of Zai’s claims. The district court reasoned that the Federal Credit Union Act’s jurisdiction-stripping provision barred the court from hearing the case, as Zai had not exhausted administrative remedies with the Board.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the district court had jurisdiction. The Sixth Circuit held that the Federal Credit Union Act’s jurisdiction-stripping and administrative-exhaustion provisions apply only to claims that arise before the Board’s claims-processing deadline. Because Zai’s claim for breach of the settlement agreement arose years after the deadline, she was not required to exhaust administrative remedies, and the jurisdictional bar did not apply. The Sixth Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "Zai v. National Credit Union Administration Board" on Justia Law